2017-11-23
Added · Updated
The Hong Kong Monetary Authority and the Treasury Markets Association launched the Enhanced Competency Framework on Treasury Management to establish industry-wide standards for professional competence and talent development. The non-statutory framework defines competency levels and certification pathways for treasury practitioners, including requirements for examinations, continuing professional development, and grandfathering arrangements for existing staff. Authorized institutions are encouraged to adopt the framework to benchmark employee skills, manage workforce development, and ensure their treasury functions are performed by qualified personnel.
Guide to Enhanced Competency Framework on Treasury Management Hong Kong Monetary Authority November 2017
Table of Contents 1 Introduction ...................................................................................................................3 2 Objectives .......................................................................................................................4 3 Scope of application .......................................................................................................5 4 Competency standards ..................................................................................................8 5 Qualification standards and certification ....................................................................8 6 Continuing professional development (“CPD”) ..........................................................9 7 Training programmes and examinations ..................................................................11 8 Grandfathering ............................................................................................................11 9 Maintenance of relevant records ................................................................................12 10 Administration of the ECF-TM ..................................................................................12 11 Accreditation ................................................................................................................12 Annex 1 – ECF-TM: Key roles and tasks for Relevant Practitioners ...........................14 Annex 2 – ECF-TM: Competency framework .................................................................17 Annex 3 – ECF-TM: Learning outcomes and topics .......................................................19 Annex 4 – Accreditation mechanism for ECF-TM ..........................................................25
1 In 2016, Mainland China’s outward direct investment (ODI) exceeded inbound foreign direct investment (FDI) and reached a record high of US$196 billion. Source: Ministry of Commerce, National Bureau of Statistics and State Administration of Foreign Exchange. “Joint Statement” Publication date: 30 September 2017. http://fec.mofcom.gov.cn/article/tjsj/tjgb/201709/20170902653690.shtml 2 In addition to the ECF on treasury management, there are five other modules introduced or to be introduced, including (i) antimoney laundering and counter-financing of terrorism (“AML/CFT”), (ii) cybersecurity, (iii) retail wealth management, (iv) credit risk management, and (v) risk management and compliance.
4 - as a clear guide to facilitate Treasury Management practitioners in upgrading their professional knowledge, technical skills and workplace behaviours along different stages of their banking career. Also, AIs will benefit from the availability of a clear framework on the competencies to pursue when acquiring, developing and managing their workforce on Treasury Management. 2 Objectives 2.1 The Enhanced Competency Framework on Treasury Management (hereinafter referred to as “ECF-TM”) is a non-statutory framework which features the common core competences required of Treasury Management practitioners in the Hong Kong banking industry. The objectives of the ECF-TM are twofold: (a) to develop a sustainable talent pool of Treasury Management practitioners for the banking industry; and (b) to raise and maintain the professional competence of Treasury Management practitioners in the banking industry. 2.2 Although the ECF-TM is not a mandatory licensing regime, AIs are encouraged to adopt the ECF for the following purposes: (a) to serve as a benchmark to determine the level of competence required and assess the ongoing competence of individual employees; (b) to support relevant employees to attend training programmes and examinations that meet the ECF-TM benchmark; (c) to support the continuing professional development of individual employees; and (d) to specify the ECF-TM as an industry-recognised qualification, including for recruitment purposes.
5 - 3 Scope of application 3.1 The ECF-TM is aimed at ‘Relevant Practitioners’, i.e. persons engaged by AIs in undertaking business activities, market and/or liquidity risk management, and product control within the Treasury Management functions. For the purpose of this ECF-TM, Treasury Management refers to: Selling and marketing of financial products and services to institutional and corporate customers Dealing and investment of financial products and services, including counterparty trading Treasury operations, asset and liability management, and risk management and control (including but not limited to market or liquidity risk management) Product development and control for new product sign-off or launch The term “financial products and services” is intended to capture common financial products sold and traded by institutional and corporate sales desks of AIs in Hong Kong. As an illustration, types of financial products under the ECF-TM will include, but not limited to, the financial products enlisted on the Code of Conduct and Practice of the TMA. Equity securities, equity-related futures, equity lending and secondary loan trading generally do not fall within the definition of “financial products and services” for the purpose of the ECFTM. However, structured products such as equity linked instruments are covered by the Code of Conduct and Practice of the TMA and should be regarded as “financial products and services” for the purpose of the ECF-TM. 3.2 Specifically, the definition of “Relevant Practitioners” for the ECF-TM includes the following job roles:
6 - Role 1 – Dealing, Selling and Investment Role 2 – Risk Management and Control Role 3 – Product Development and Control Role Descriptions of Relevant Practitioners at Core Level (Please refer to the key tasks specified in Annex 1 for the detailed definition of each role) Supporting trading activities, conducting simple financial market activities and supporting the sales of financial products to institutional or corporate customers Supporting treasury-related risk management control (including but not limited to market and/or liquidity risk management) and reporting Not applicable Role Descriptions of Relevant Practitioners at Professional Levels I and II (Please refer to the key tasks specified in Annex 1 for the detailed definition of each role) Conducting financial market and Treasury Management activities, selling financial products to institutional and corporate customers, and formulating Treasury Management strategies Monitoring performance of investments carried out by deals and investment operational departments, enforcing and reviewing risk limits and exceptions (including but not limited to market and/or liquidity risk management) Identifying and developing new financial products, performing due diligence on new products, seeking sign-off from other control functions in the AI 3.3 The definition of ‘Relevant Practitioners’ recognises differences among AIs in how the Treasury Management practitioners are allocated within their organisational structure (e.g. as a unit within the AI’s treasury department or as part of the commercial banking). To facilitate the determination of whether a staff member falls under the scope of “Relevant Practitioners”, the key tasks of different job roles are specified in Annex 1 as guidance. 3.4 It is intended that the ECF-TM applies to staff performing Treasury Management roles with key tasks specified in Annex 1 and it is not intended to capture staff performing other job functions that are incidental to Treasury Management (e.g. legal counsels, general risk compliance officers, financial reporting, internal auditors and ancillary staff responsible for administrative functions in the treasury / risk function).
7 - 3.5 In addition, the following categories of staff do not fall within the definition of ‘Relevant Practitioners’: (a) Staff in the Treasury Management functions performing solely clerical and administrative duties. (b) Staff responsible for back office functions (e.g. confirmation or settlement of trade). (c) Staff responsible for general risk management, reporting and compliance of the entire organisation rather than Treasury Management, or providing support to Treasury Management on an ad hoc rather than an ongoing basis. (d) Staff responsible for tasks operating outside Hong Kong, e.g. staff providing financial products and services executed or conducted outside Hong Kong. 3.6 For avoidance of doubt, a staff member is not required to work full time in Treasury Management or perform all of the roles specified in Annex 1 in order to be classified as a Relevant Practitioner. A principle-based approach can be adopted by AIs in determining whether a staff member with multiple job roles falls within the definition of Relevant Practitioners for the ECF-TM, based on the significance and permanence of the Treasury Management role performed by the staff member. AIs should be able to justify decisions made in this regard. 3.7 If the Treasury Management functions of an AI are outsourced, AIs should ensure that the outsourced functions are performed by competent personnel who possess the ECF-TM or other comparable qualifications.
8 - 4 Competency standards 4.1 Competency standards are set at three levels: a) Core level This level will be applicable to entry-level staff in Treasury Management b) Professional level I This level will be applicable to staff who are specialising in Treasury Management c) Professional level II This level will be applicable to staff who are taking charge of middle to senior management roles in Treasury Management 4.2 The competency framework for the ECF-TM, detailing the key tasks, qualifications and continuing professional development requirements for each key role, is included in Annex 2. 5 Qualification standards and certification 5.1 Qualifications are set at three levels in accordance with the three competency standards (i.e. Core Level qualification, Professional Level I qualification and Professional Level II qualification). 5.2 Relevant Practitioners shall be eligible for qualification under the ECF-TM given satisfactory certification of one or more of the qualification requirements as specified under the ECF-TM. Details of the qualification requirements and the learning topics are set out in Annex 2 and Annex 3 respectively. 5.3 Upon attaining the qualifications and fulfilling the minimum work experience requirements, Relevant Practitioners may apply to the ECF-TM administrator, TMA, for certification as Associate Treasury Management Professional (ATMP), Certified Treasury Management Professional (CTMP), or Certified Senior Treasury Management Professional (CSTMP) under the ECF-TM. The specific conditions for ECF-TM certification are as follows:
9 - a) ATMP: Successful completion of the Core Level certification (no minimum work experience is required) b) CTMP: Successful completion of the Professional Level I certification plus at least 3 years of relevant work experience c) CSTMP: Successful completion of the Professional Level II certification plus at least 5 years of relevant work experience 5.4 A Relevant Practitioner may also apply to the TMA for certification as ATMP and CSTMP through the grandfathering path, where applicable. The grandfathering arrangements are set out in section 8. 5.5 The ECF-TM certificate is subject to annual renewal by TMA together with the renewal of the certificate holder’s membership of TMA. A Relevant Practitioner is required to: a) Complete the annual continuing professional development requirement; and b) Pay an annual membership fee to renew his/her ECF-TM certificate and TMA membership. 5.6 The ECF-TM is referenced to the Qualifications Framework (“QF”), with the Core Level being pitched at QF Level 4 (i.e. equivalent to associate degree or higher diploma level) and the Professional Level at QF Level 6 (i.e. equivalent to postgraduate certificate level). 6 Continuing professional development (“CPD”) 6.1 Holders of ECF-TM certification are required to undertake the following minimum CPD requirements: • Core level - a minimum of 10 CPD hours in each calendar year. • Professional level - a minimum of 20 CPD hours in each calendar year.
10 - The CPD hours for Core and Professional levels are recommended with reference to similar continuous development requirements in respect of investment or risk management professional qualifications offered by international institutions. 6.2 CPD activities should be of significant intellectual and practical contents which involve interaction with other individuals or fulfilment of assignments and examinations. Activities that qualify for CPD include: a) Attending seminars or courses provided by AIs, recognised professional bodies and academic and training institutions, and TMA; b) Attending overseas training; c) Attending professional examinations; d) E-learning (maximum 2 hours for Core level; maximum 5 hours for Professional level); e) Self-study activities (maximum 2 hours for Core level; maximum 5 hours for Professional level) f) Luncheon talks; and g) Delivering training and speeches. 6.3 CPD training topics should be related to financial markets or the job functions: a) Product knowledge b) Legal and compliance c) Risk management d) Economic and quantitative analysis e) Business and accounting analysis & management f) Supervisory & management skills 6.4 The annual CPD requirements are also applicable to Relevant Practitioners meeting the ECF-TM benchmark through the grandfathering route. 6.5 The CPD requirements will be waived for the first calendar year (ending 31 December) of certification and grandfathering.
11 - 6.6 The lists of CPD activities and training topics are subject to TMA’s review from time to time. For details, please refer to the TMA’s website (https://www.tma.org.hk/). 7 Training programmes and examinations 7.1 Relevant Practitioners can meet the ECF-TM benchmark by undertaking: a) TMA Level 1 or Level 2 training programmes or accredited training programmes; and b) passing examinations accredited by TMA. 8 Grandfathering 8.1 A Relevant Practitioner may be grandfathered on a one-off basis based on the following grandfathering arrangements: a) ECF-TM Core Level may be granted where the applicant is: • Existing TMA Associate Member; and • Employed by an AI at the time of application b) ECF-TM Professional Level may be granted where the applicant is: • Existing TMA Full Member or Fellow Member; and • Employed by an AI at the time of application 8.2 Existing Relevant Practitioners meeting the above criteria can submit their grandfathering applications to the TMA, administrator of the ECF-TM, on or before the deadline of 31 December 2018. Those who are working in an AI but not a current TMA member could apply for grandfathering during 2 January 2018 to 31 December 2018 if they are admitted as a TMA Associate or Full Member according to TMA’s prevailing membership policies. 8.3 Any other individuals performing the job roles outlined in paragraph 3.2 but not working in an AI or those specified in paragraph 3.5(a) to (d) of an AI during the grandfathering application period may submit their applications to the TMA for grandfathering within three months from the date of joining the Treasury Management functions of an AI and becoming a Relevant
12 - Practitioner. However, they should have met all the applicable grandfathering criteria on or before 31 December 2018 as prescribed by the TMA. 8.4 Applications for grandfathering are handled by the TMA subject to the prevailing TMA annual membership fee. If required, the TMA may request the applicant to provide employment records or additional information to substantiate the application for grandfathering. Late application will not be accepted. 9 Maintenance of relevant records 9.1 AIs should keep proper training, examination, certification and CPD records of Relevant Practitioners for monitoring implementation of plan for developing staff competencies or for other talent management purpose. AIs are expected to support their staff to apply for grandfathering and certification. Regarding information related to a Relevant Practitioner’s previous employment(s), the current employer is encouraged to provide the necessary assistance to Relevant Practitioners in the latter’s applications for grandfathering or ECF certification (e.g. confirming whether such information is consistent with the curriculum vitae provided by the Relevant Practitioner at the time of job application). 10 Administration of the ECF-TM 10.1 The TMA is the administrator of the ECF-TM and will be tasked with handling applications for certification and grandfathering under the ECF-TM. The TMA will also administer the CPD requirements as set out under the ECF-TM. For details, please refer to the TMA’s website (https://www.tma.org.hk/). 11 Accreditation 11.1 The ECF accreditation mechanism is established for interested AIs or education and training operators to have their learning programmes accredited as meeting the ECF standards (including but not limited to the Qualifications Framework (QF) Standards) of this ECF module.
13 - 11.2 The general criteria for ECF accreditation are as follows: (a) The training programme meeting the required standards of individual ECF modules including programme objectives and learning outcomes, programme content and structure, and trainer qualifications and learning mode; (b) Accreditation of the training programme at corresponding QF Levels; and (c) Endorsement by the ECF Steering Committee. 11.3 In order to satisfy criteria 11.2 (a) and (b) outlined above, (a) For self-accrediting institutions (e.g. institutions funded by the University Grants Committee, including their continuing education arms) / institutions with Hong Kong Council for Accreditation of Academic and Vocational Qualifications (HKCAAVQ) Programme Area Accreditation (PAA) status, they are required to: (i) complete internal quality assurance processes to ensure the training programmes are meeting the relevant ECF standards and the corresponding QF Level and (ii) be assessed by HKCAAVQ as fulfilling the ECF training objectives (b) For other institutions, they are required to be accredited by HKCAAVQ as fulfilling the ECF training objectives and meeting the corresponding QF Level 11.4 HKCAAVQ will accept applications for ECF accreditation starting 2 January
11.5 Based on the relevant accreditation or assessment report submitted by the applicant, the ECF Steering Committee will confirm whether the training programme is or is not successful to qualify as an ECF accredited programme. The route for ECF accreditation mechanism is illustrated at Annex 4.
Role 1 – Dealing, Selling and Investment Role 2 – Risk Management and Control Core Level Suitable for entry-level staff in Treasury Management Examples of functional title Junior Dealer, Dealer, Treasury Sales Officer, Treasury Operations Assistant Assistant Market Risk Analyst, Assistant Market Risk & Product Manager Key tasks 1. Assist with financial markets activities
16 -
Supervise the activities of treasury dealers within the AI
17 - Annex 2 – ECF-TM: Competency framework Role 1 – Dealing, Selling and Investment Role 2 – Risk Management and Control Core Level Suitable for entry-level staff in Treasury Management Role description (Please refer to the key tasks set out in Annex 1 for the detailed definitions of each role) Supporting trading activities, conducting simple financial market activities and supporting the sales of financial products to institutional or corporate customers Supporting treasury-related risk management control (including but not limited to market and/or liquidity risk management) and reporting Qualification • Bachelor’s or higher degree with major in areas of Economics, Finance, Corporate Finance, Risk Management, Investment Management, Asset Management, Quantitative Finance, Financial Engineering and Accounting: Passing the Elementary Level examination on TMA Code of Conduct and Practice (TMA CCP); or • Others: Passing TMA Level 1 – Professional Certificate in Treasury Markets (QF Level 4) Certification • Associate Treasury Management Professional TMA Membership • TMA Associate Member with Core Competency CPD requirements • Minimum 10 CPD hours in each calendar year
recognised CPD activities include attending seminars or courses provided by AIs, recognised professional bodies and academic and training institutions, and TMA; attending professional examinations, e-learning (maximum 2 hours), luncheon talks; and delivering training and speeches
a maximum of 2 hours’ self-study activities • CPD training topics should be related to financial markets or the job functions: product knowledge, legal and compliance, risk management, economic and quantitative analysis, business and accounting analysis & management, and supervisory & management skills
18 - Annex 2 – ECF-TM: Competency framework Role 1 – Dealing, Selling and Investment Role 2 – Risk Management and Control Role 3 – Product Development and Control Professional Level For staff taking up middle and senior positions in Treasury Management Role description (Please refer to the key tasks set out in Annex 1 for the detailed definitions of each role) Conducting financial market and Treasury Management activities, selling financial products to institutional and corporate customers, and formulating Treasury Management strategies Monitoring performance of investments carried out by deals and investment operational departments, enforcing and reviewing risk limits and exceptions (including but not limited to market and/or liquidity risk management) Identifying and developing new financial products, performing due diligence on new products, seeking sign-off from other control functions in the AI Qualification and experience (Professional Level I – Relevant practitioners who are specialising in respective function) • Passing TMA Level 2: Postgraduate Certificate in Banking and Corporate Treasury Management (QF Level 6)
M1 Banking and Corporate Treasury Management; and
M2 Treasury Products and Financial Risk Management; and • Having at least 3 years’ relevant experience • Passing TMA Level 2: Postgraduate Certificate in Banking and Corporate Treasury Management (QF Level 6)
M2 Treasury Products and Financial Risk Management; and
M3 Treasury Risk Management and Compliance; and • Having at least 3 years’ relevant experience Qualification and experience (Professional Level II – Relevant practitioners who are taking charge of middle to senior management roles of the respective function) • Passing TMA Level 2: all three modules of the Postgraduate Certificate in Banking and Corporate Treasury Management (QF Level 6); and • Having at least 5 years’ relevant experience Certification • Professional Level I: Certified Treasury Management Professional • Professional Level II: Certified Senior Treasury Management Professional TMA Membership • Professional Level I: TMA Associate Member with Professional I Competency • Professional Level II: TMA Full Member with Professional II Competency CPD requirements • Minimum 20 CPD hours in each calendar year
recognised CPD activities include attending seminars or courses provided by AIs, recognised professional bodies and academic and training institutions, and TMA; attending professional examinations, e-learning (maximum 5 hours), luncheon talks; and delivering training and speeches
a maximum of 5 hours’ self-study activities • CPD training topics should be related to financial markets or the job functions: product knowledge, legal and compliance, risk management, economic and quantitative analysis, business and accounting analysis & management, and supervisory & management skills
19 - Annex 3 – ECF-TM: Learning outcomes and topics I. Core Level (Benchmarked at QF Level 4)
20 - 2.3 Interest rate and the economy Borrowing and lending maturities Factors affecting interest rates determination Short-term money market instruments 2.4 Debt and capital markets • Basic features of a bond (coupon, principal, maturity, price, yield and credit quality) • Bond issuing and investing (issuers, investors, indexes, pricing and investment risks) • Types of bonds (classification by properties and characteristics and by issuers) • Bond markets (primary and secondary markets) and development of RMB bonds • Types of equity securities and the Hong Kong Stock Exchange 2.5 Derivatives and commodities markets • Futures and forwards
Characteristics and differences
Types of forward and futures transactions and market participants
Settlement and delivery procedures
Over-the-counter markets
Hedging • Types of swaps (interest rate, cross-currency and credit default) • Options
Factors affecting an option’s value
Delivery and settlement
Credit options, options in other financial markets and exotic options • Structured products • Precious metals and other commodities markets (market features, participants and pricing fundamentals) 2.6 Operations and risk management • Introduction to risk management • Operational risk
Internal and external fraud
Employment and business practices
21 -
Business disruption, system failure and contingency • Basel Committee’s ten principles for managing operational risks 2.7 Ethics and compliance • Code of Conduct and Practice of TMA (Elementary Level) • Overview of legal and regulatory framework in Hong Kong II. Professional Level (Benchmarked at QF Level 6)
22 - Current development of RMB market 2.2 Banking treasury management • Treasury roles and banking treasury organisational structure • Treasury policies and performance measurement • Bank asset and liability management • Balance sheet management, foreign exchange exposure and portfolio management • Liquidity management in global treasury market operations and strategies for managing Liquidity Coverage Ratio and Net Stable Fund Ratio • Capital requirements in banking funding and lending • Cash pooling application • Internal fund pricing implementation 2.3 Corporate treasury management Corporate asset and liability management Cashflow management and cash management Global financial and credit management Corporate treasury policies and governance Cross-border lending for multinational corporations Tax Regime development and tax treaty network in Hong Kong RMB cross-border cash management Financial accounting tools applications Hedge accounting treatment and applications Treatments in central clearing counterparty, credit value adjustment and fair value adjustment 2.4 Treasury products • Money market products • Foreign exchange products • Equity products • Structured products • Dealing and structuring of treasury products • Bond market development of Hong Kong and Mainland China
23 - 2.5 Interest rate securities and derivatives • Short-term and long-term debt instruments • Mortgage-backed securities, asset-backed securities, convertible bonds, hybrid securities • Bond futures, forward rate agreements, interest rate swaps, credit default swaps • RMB offshore products • Yield curve and term structure of interest rates • Default risk, credit spread risk, and interest rate risk • Dispersion trade • Role of rating agencies 2.6 Hedging and trading strategies • Pricing and valuation models of derivatives • Multi-currency debt management • Risk factors involved in using treasury products • Managing market risk through hedging • Currency hedging and trading simulation • Application of interest rate swap trading • RMB risk management 2.7 Treasury risk management and practices • Principles of treasury risk management • Effective risk management framework • Essential practices for risk management • Types of treasury risk • Counterparty risk management • Balance sheet risk management • Credit risk management • Scenario analysis, back testing and stress testing • Asset and Liability Management Committee (ALCO) governance model • Emerging best practices risk governance
24 - 2.8 Financial regulations and compliance • Regulatory framework for treasury market activities • Basel III capital and liquidity rules • Rules and guidelines relevant to treasury operations in Hong Kong and Mainland China • Disclosure standards and compliance • Code of Conduct and Practice of TMA (Advanced Level) • BIS foreign exchange global code • Anti-money laundering and counter financing of terrorism related requirements and other current issues of treasury compliance in Hong Kong
25 - Annex 4 – Accreditation mechanism for ECF-TM Subject to re-accreditation/re-assessment by HKCAAVQ Endorsement by ECF Steering Committee Applicant to notify HKMA the intention of obtaining accreditation with programme objectives & learning outcomes, programme syllabus, training materials, and trainers’ profile for record Obtain ECF and QF accreditation through HKCAAVQ Submit proof on ECF and QF accreditation Training programme accredited for ECF Register on the QR Submit proof on ECF assessment